Anti-Money Laundering (AML) Policy

Important: This Anti-Money Laundering (AML) Policy is a mandatory part of your agreement with AlphaEdge Partners Limited. All users must comply with the requirements set out in this policy. Failure to comply may result in account suspension, termination, and/or legal action.

1. Policy Statement

AlphaEdge Partners Limited ("AlphaEdge", "we", "our", or "us") is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes across every account, transaction, and relationship on the Platform. We operate with the highest standards of integrity, transparency, and regulatory compliance.

We comply with all applicable laws and regulations relating to anti-money laundering and counter-terrorist financing, including:

• The Money Laundering Regulations 2017 (United Kingdom).
• The Proceeds of Crime Act 2002 (United Kingdom).
• The Terrorism Act 2000 (United Kingdom).
• The Nigeria Money Laundering (Prevention and Prohibition) Act 2022.
• Applicable Financial Action Task Force (FATF) recommendations.
• Relevant United Nations Security Council Resolutions on sanctions.

This policy applies to all employees, contractors, service providers, and users of our Platform. We are committed to a culture of compliance, and we will take all reasonable steps to prevent our services from being used for financial crime.

2. Customer Due Diligence (CDD)

We conduct thorough Customer Due Diligence (CDD) on all users to verify identities, assess risk, and comply with regulatory requirements. Our CDD process includes:

3. Transaction Monitoring

We continuously monitor transactions on our Platform to identify unusual or suspicious activities. Our monitoring systems are designed to detect patterns and behaviours that may indicate:

• Money laundering.
• Terrorist financing.
• Fraud or other financial crimes.
• Sanctions violations.
• Structuring or "smurfing" (breaking large transactions into smaller amounts to avoid detection).
• Transactions inconsistent with the user's profile or normal activity.

Monitoring is both automated and manual. We use advanced analytics and transaction scoring to flag potential risks. Trained compliance staff review flagged transactions and take appropriate action.

4. Suspicious Activity Reporting

When we detect suspicious activity, we may take the following actions:

• File Suspicious Activity Reports (SARs) with the relevant authorities, such as the National Crime Agency (NCA) in the UK or the Nigerian Financial Intelligence Unit (NFIU).
• Freeze assets or restrict account activity pending investigation.
• Delay or reject transactions that appear suspicious.
• Notify law enforcement where appropriate.
• Terminate business relationships where necessary.

Important: We are prohibited by law from disclosing to users or third parties that we have filed a Suspicious Activity Report or conducted an investigation, except as required by law.

5. Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public position. PEPs are considered higher risk for money laundering due to the potential for corruption and misuse of public funds.

We screen all users against global PEP databases. If you are identified as a PEP, you will be subject to:

• Enhanced Due Diligence.
• More frequent transaction monitoring.
• Additional documentation requirements.
• Management-level approval for account opening and certain transactions.

Family members and close associates of PEPs may also be treated as PEPs under applicable regulations.

6. Sanctions Compliance

We comply with all applicable sanctions regimes, including those issued by:

• United Nations Security Council — Global sanctions against individuals and entities.
• UK Office of Financial Sanctions Implementation (OFSI) — UK sanctions.
• US Office of Foreign Assets Control (OFAC) — US sanctions.
• European Union — EU sanctions.
• Nigeria Sanctions Committee — Nigerian sanctions.

We screen all users and transactions against global sanctions lists. If a match is found, we will:

• Block the transaction.
• Freeze the account.
• Report the match to relevant authorities.
• Refuse to open an account.

We do not conduct business with individuals or entities on sanctioned lists.

7. Record Keeping

We maintain detailed records of all customer due diligence, transactions, and compliance activities in accordance with applicable regulations. Records are retained for the following periods:

• KYC Documents — Retained for 7 years after account closure.
• Transaction Records — Retained for 7 years from the date of transaction.
• SAR Reports — Retained indefinitely.
• Correspondence — Retained for 7 years.

Records are stored securely and are accessible to relevant compliance and regulatory authorities upon request.

8. Employee Training and Awareness

All AlphaEdge Partners Limited employees and contractors undergo mandatory AML training upon hiring and annually thereafter. Training covers:

• Money laundering and terrorist financing risks.
• Identification and reporting of suspicious activity.
• KYC and CDD requirements.
• Sanctions compliance.
• Data protection and confidentiality obligations.
• Reporting procedures and internal escalation.

We promote a culture of compliance where all staff are encouraged to raise concerns about potential financial crime.

9. Independent Audits and Reviews

We engage independent third-party auditors to conduct periodic reviews of our AML program. These audits assess:

• Compliance with regulatory requirements.
• Effectiveness of internal controls.
• Quality of customer due diligence.
• Transaction monitoring systems.
• Employee training and awareness.
• Record keeping and documentation.

Audit findings are reported to our Board of Directors and used to continuously improve our AML program.

10. Non-Compliance and Consequences

Non-compliance with this AML Policy may result in:

• Account Suspension — Temporary or permanent suspension of your account.
• Asset Freeze — Freezing of funds held in your account.
• Account Termination — Closure of your account and termination of your relationship with AlphaEdge.
• Legal Action — Civil or criminal proceedings.
• Reporting — Reporting to regulatory authorities and law enforcement.
• Forfeiture — Forfeiture of funds to the relevant authorities where required by law.

We take non-compliance seriously and will enforce this policy rigorously to protect our Platform and our users.

11. Updates to This Policy

We may update this AML Policy from time to time to reflect changes in law, regulation, or our operational practices. When we make changes, we will:

• Update the "Effective Date" at the top of this policy.
• Post the updated policy on this page.
• Provide notification of significant changes through the Platform or via email.

Continued use of our services after an update constitutes acceptance of the revised Policy.

12. Contact

For questions about this AML Policy, to report suspicious activity, or to make a complaint, contact our Compliance Officer:

We maintain a confidential reporting channel for staff and users to report concerns. Reports can be made anonymously where permitted by law.